Corporate Disclosure in Compliance with California Transparency in Supply Chain Act (SB-657)

A core foundation of Hampton Products’ business model is to conduct business in a responsible and ethical manner in all aspects of everyday activity. Hampton understands that to become a better company, it is important to continue to advocate human rights and safety in the work place not only for direct associates, but for those individuals that take any part in the production of our products.

On January 1, 2012, The California Transparency in Supply Chains Act of 2010 went into effect. The law requires that retailers and manufacturers doing business in California disclose their efforts to address the issue of slavery and human trafficking in their supply chains. The disclosure allows consumers to make informed choices about the products they buy and the companies they choose to support.

In our own commitment to be a responsible company, Hampton requires every supplier to sign an agreement that they, their contractors, and their sub-contractors will abide by certain standards set forth in the Supplier Guide and Code of Business Conduct (SGCBC). The standards cover topics including voluntary employment, wages, working hours, human rights and discrimination, workplace and environmental protection, and addresses child labor.

Specifically, the Hampton Products SGCBC states the following for “Forced Labor”:

Employment Standards: Suppliers are expected to operate in a manner consistent with the beliefs of Hampton Products. This includes and is not limited to the hiring of employees who are, in all cases, present and employed voluntarily, not put at risk of physical harm due their work environment, fairly compensated and allowed the lawful right of free association.

Hampton Products also monitors child labor in the supply chain and is addressed in the SGCBC as follows:

Child Labor: Hampton Products will not tolerate the use of child labor. No person should be hired at an age younger than the legal minimum age for the country of operation, but in no case, at an age of 14 years or younger.

Verification

In addition to the contractual obligations Hampton Products sets forth to our suppliers, many of our factories undergo periodic assessments performed by on-site visits by Hampton Corporate Officers. In addition to building stronger relationships with each supplier, it allows the decision makers to see first-hand the operations and working conditions that go in to making our products.

Supplier Audits

Many of Hampton Products’ suppliers undergo periodic audits from 3rd party Social Auditing companies. Some of the audits are announced, and some are not. Upon completion of all audits, identified issues are discussed, rectified, documented and re-audited to insure systematic change.

Supplier Certifications

By Signing the Hampton Products SGCBC, Suppliers Certify that they have read and understand the requirements set forth in the SGCBC and their willingness to comply with those requirements including those related to forced labor and child labor as specified above.

Internal Accountability

Hampton Products requires all associates, suppliers, contractors and service providers to act ethically and comply with all company policies. If policies are allegedly violated, a formal inquiry into the issue is commenced to determine appropriate action; up to and including termination of associates and termination of supplier / contractor agreements.

Training

Hampton Products trains supply-chain decision makers such as merchandisers, buyers and factory sourcing individuals on how to identify and respond to issues such as forced and child labor. Employees are also encouraged to reinforce to all suppliers the importance of appropriate factory labor practices.